Harlow v. Harlow, No. 05-22-00585-CV, 2023 WL 3220919 (Tex. App. Dallas May 3, 2023, no pet. h.).
The Dallas Court of Appeals held that a county court at law lacked jurisdiction over a trust because it was not a matter related to a probate proceeding. The inter vivos trust was not created by a decedent whose will was admitted to probate as required by Estates Code § 31.002(b)(3) because the decedent died intestate.
Moral: It is essential to litigate trust issues in a court with subject matter jurisdiction because subject matter jurisdiction can neither be presumed nor waived.